I can see this as the tip of the iceberg. Here is an organization that is trying to comply with the mandate, but for whatever reason (funding, material availability, technical issues, etc.) they will probably not meet the deadline. They have done their due diligence, but cannot finish in time.

I see more waiver requests like this coming in as the deadline draws near and organizations are finding themselves running out of time. They are not intentionally trying to beat the system, but are running up against a wall that they have little if any control over.

For the FCC: Perhaps it’s time to start hiring new people to handle the influx of waivers when they start coming in. Remember, it was just a small iceberg in the distance that sunk the Titanic.

Much like some of the articles we have seen since this bill was passed out of committee, our Regional Wireless Cooperative (RWC) staff and subject matter experts have some of the same reservations regarding an arbitrary "give-back" provision without a more defined plan for a future transition. Here are some of our talking points and questions:

• Generally, the RWC has been supportive of the nationwide broadband data effort, but NOT at the expense of giving up narrowband channels;

• There is a long way to go before we will see a product that satisfactorily provides both data and voice;

• There is something to be said for not putting all our public-safety technology eggs in one basket; in other words, broadband data versus voice;

• Currently if data fails, we can fall back on voice and vice versa;

• If voice and data are running on the same system there is much greater potential that, in the event of a system failure, we will lose both voice and data;

• With broadband, voice will simply be another data component;

• Costs will be a critical factor. The RWC has a tremendous amount invested in its network and are about to invest a lot more. Today, our best estimates are $50 million in infrastructure to transition to 700 MHz narrowband and more than $100 million in member subscriber equipment;

• The costs associated with the new broadband network are unknown and may not be fully realized for many years;

• How much will the RWC have to invest in this new technology? Will it be cost effective for a provider to make the investment on its own and then sell service to the limited public-safety community?

• It is one thing to share a data service with commercial users who have lower priority, but this model may not work well for voice;

• What is the timeframe when the RWC will have to give up our narrowband channels so the broadband network can expand to take over voice?

• Transition issues and costs could be staggering for our RWC members.

As you can see, we have many questions regarding how the transition will be managed and at what cost. Until these questions are better answered, the RWC does not support the provisions in the bill that require a giveback of 700 MHz narrowband spectrum.

David Felix

Executive Director

Arizona Regional Wireless Cooperative (RWC)

Editor:

This draft bill actually will set back interoperability efforts between agencies that we have patched together since 9/11. The draft bill redefined public-safety services to an extremely limited scope, comprising only law enforcement, fire and medical first response. That limitation is a danger to the public and will reduce the effectiveness of state and local agencies to provide critical emergency response and incident management for the public.

In its fourth report and order in response to the city of Charlotte, N.C., in July regarding eligibility of users for a public-safety broadband system, the FCC recognized the key role transportation agencies perform in the protection of life, health and property and confirmed transportation as a critical public-safety first responder. State and local transportation assets are frequently the first of all first responders required to respond to an event to clear roads of trees, flooding and hazardous spills and provide critical traffic management so that law enforcement and medical can make their way to a scene, or otherwise perform their critical functions. By eliminating valuable transportation assets as primary users of regional broadband networks, this bill will prevent the necessary real time sharing of situational awareness between all required responders, and actually set back the interoperability efforts that regional and local diverse, multiagency committees have successfully patched together across the nation during the past 10 years.

To accomplish the primary purpose of this bill, the section that redefines the targeted users to an overly restrictive and dangerously narrow scope must be eliminated or substantially reworded.

Bill Brown

Chairman

Special Committee on Wireless Communications Technologies

American Association of State Highway and Transportation Officials

Editor:

Not a whole lot of research was done for this bill. Arizona is in the process of a statewide buildout in 700 MHz along with several other states. Pima and Maricopa County are each putting $200 million into their systems. Yuma, La Paz and several tribes are partnering with Arizona Department of Public Safety and the Arizona Department of Transportation to put in a statewide system. Many other smaller systems exist in Arizona let alone other states. Hopefully someone will inform the lawmakers prior to this bill coming up.

Greg Wilkinson

City Administrator

Yuma, Ariz.

Editor:

This legislation, if successfully passed, will result in plenty of jobs … for attorneys!

Dennis Story

Editor:

Everything about this bill looks very good, except the requirement for public safety to give up the 700 MHz narrowband spectrum. That is completely out of line and uncalled for. What is the purpose of this strategy?

As it stands, public safety is short at least 25 megahertz of spectrum, including the 700 MHz portion. Public safety should receive more spectrum rather than have it taken away. The VHF narrowbanding has provided little if any relief to spectrum already at maximum capacity, and UHF or T-band is in the same shape.

I would remove this public safety return stipulation from the bill and push it through. Not removing the give-back requirement of this bill is only going to cost the lives of our public-safety officers and the citizens they serve.

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